RECORDS MANAGEMENT GUIDANCE & PROCEDURES

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Procedure identification

Procedure Ownership

Department Communications Unit (Compliance Section)

Owner Joanne Meadows

Approval

CSOP (as required) 14.02.2012

Board (as required)

Version

Version Final

Date of Issue 20.04.2012

Implementation From 20.04.2012 To

Review Date 16.08.16

Date(s) of Reissue

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CONTENTS

Page

Foreword 1. Introduction 7 1.1 Principles of Good Records Management 7 1.2 Legal Requirements 8 1.3 Roles and Responsibilities 10 2. Records Management Principles 2.1 What is a record? 13 2.2 Why do you need to keep records? 14 ` 2.3 What information must be recorded? 14 2.4 What information should not be recorded? 15 2.5 The importance of good filing practices 15 2.6 Storage methods for manual information 15 2.7 What happens if we don’t manage our records? 16 3 Security of Records 17 3.1 Sensitive/Protectively marked information 18 3.2 Protective Markings 18 3.3 Security Measures 18 3.4 Security of Electronic Records 22 3.5 Secure Destruction of Records 22 4. Operational Records Management Procedures 23 4.1 Operational Records 23 4.2 Operational Records held on PIMS 23 4.2.1 Probation Management System (PIMS) 23 4.2.2 Creation of a PIMS record 23 4.2.3 Titling 23 4.2.4 Content 24 4.2.5 Filing/Storage 24 4.2.6 Auditing and Monitoring 24 4.2.7 Scanning Documents onto PIMS 24 4.2.8 Closing and Disposal 24 4.3 Manual Operational Records 24 4.3.1 Titling 24 4.3.2 Content 25 4.3.3 Handwritten Notes for Pre-sentence Reports 25 4.3.4 Storage of Manual Operational Records 26 4.3.5 Storage of High Risk Operational Records 26 4.3.6 Tracking Current Manual Operational Files 27 4.3.7 Tracking Closed Manual Operational Records 27

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CONTENTS Page

4.4 Closing & Disposal Arrangements for Operational Records 27 4.4.1 Closing 28 4.4.2 Disposal Arrangements 29 4.4.3 Determined upon Review 29 4.4.4 Relevant Manager authorises destruction 29 4.4.5 Permanent Preservation 31 4.4.6 Destroy 31 5. Corporate Records Management Procedures 32 5.1 Corporate Records 32 5.2 File Creation 32 5.3 Registration of Records 32 5.3.1 The Register 33 5.3.2 Registering and Referencing Files 33 5.3.3 File Titles 33 5.3.4 Corporate File Covers 29 5.4 Contents of a Registered File 35 5.5 Filing 36 5.5.1 Practical Points for Manual Filing 37 5.6 Arrangement of Papers in a Corporate Record 38 5.7 Storage of Corporate Files 38 5.8 Tracking Corporate Records 38 5.9 Closing Corporate Files 39 5.10 Disposal Arrangements for Corporate Records 39 5.11 Determined upon review 40 5.12 Relevant Manager authorises destruction 40 5.13 Permanent Preservation 42 6. Managing Electronic Documents in Microsoft Office 43 6.1 Naming conventions for Electronic Documents 43 6.2 Version Control 45 6.3 Filing Electronic Documents 47 6.3.1 Holding personal information electronically 48 6.4 Deleting Information 48 6.5 Managing Emails 48 7. Business Continuity 52 7.1 Risk Register 53 7.2 Storage Conditions 53

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CONTENTS Page

Appendix 1 File Tracking Sheet 55 Appendix 2 Closed File Spreadsheet 56 Appendix 3 Offender Label Template 57 Appendix 4 File Register 58 Appendix 5 File Closure Sheet 59 Appendix 6 First Review 60 Appendix 7 Second Review Form 61 Appendix 8 Document Control Sheet 62 Appendix 9 Records Management Do’s and Don’ts 63 Appendix 10 Team/Department Codes for Registration 65 Appendix 11 Off-site Storage Facility – Procedures 66 Appendix 12 Sources 71 Appendix 13 Retaining Handwritten Notes 72 Appendix 14 Guidance attaching signed documents to PIMS 73 Appendix 15 Risk analysis on scanned documents 78 Glossary 79

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FOREWORD It is the Board’s responsibility to provide a Records Management System for every part of the organization and to maintain, retain or dispose of its records in accordance with legislative and administrative requirements. All businesses, both in the private and public sectors, create information held electronically and on paper. Excessive retention of records once they have outlived their usefulness is a waste of resources and is contrary to the Data Protection Act. PBNI records should only be retained for periods that are determined by legislative and administrative needs. In addition, many records lose their value over time and storing such material in prime office space is not only wasteful but also leads to retrieval problems and the increased likelihood of the haphazard destruction of records. It is essential therefore to maintain an efficient Records Management System, not only for our own protection and convenience but also to help fulfill the Board’s statutory obligations under the Public Records Act (NI) 1923, Disposal of Records Order (S.R&O 1925 No.167) the Data Protection Act 1998 and the Freedom of Information Act 2000 which incorporates Section 46 – The Lord Chancellor’s Code of Practice for Records Management. This guidance and procedures support the Board’s policy on the management of information.

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1. INTRODUCTION PBNI is committed to creating, keeping and managing records that document its operational and corporate functions. The aim of this guidance and procedures is to:

Improve the quality of records

To maintain records control systems

To improve information retrieval through good filing systems 1.1 Principles of Good Records Management

The guiding principle of records management is to ensure that information is available when and where it is needed, by those entitled to access it, in an organized and efficient manner, and in a well-maintained environment. In order to do this, PBNI must ensure that records are: Authentic – it must be possible to prove that records are what they purport to be and who created them by keeping a record of their management through time. The record keeping system will operate so that the records derived from it are credible and authoritative. Accurate – records must accurately reflect the transactions that they document. Accessible – records must be readily available when needed. Complete – records must be sufficient in content, context and structure to reconstruct the relevant activities and transactions. Comprehensive – records must document the complete range of PBNI’s business. Compliant – records must comply with any record keeping requirements resulting from legislation and other relevant regulations. Effective – records must be maintained for specific purposes and the information contained in them must meet these purposes. Records will be identified and linked to the business process to which they are related. Secure – records must be securely maintained to prevent unauthorised access, alteration, damage or removal. They must be stored in a secure environment, with the degree of security reflecting the sensitivity and importance of the contents. Where records are migrated across changes in technology, PBNI must ensure that the evidence remains authentic and accurate. Records must be

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transmitted or transferred by secure methods and the procedures which are in place to ensure the secure transmission of information within PBNI and to outside bodies must be adhered to. Additionally these systems must be continuously reviewed to ensure ongoing protection. Further information can also be obtained from the suite of security documents in the IT section of the PBNI intranet. 1.2 Legal Requirements

PBNI will take all possible steps to ensure compliance with current and future legislation in the area of Records Management. These procedures and guidance take into account the following: Public Records Office for Northern Ireland (PRONI) PRONI was established in 1923 as the National Archive to receive and preserve the records of Government Departments, Non-departmental Public Bodies and Local Authorities. Acting on behalf of the Department of Culture, Arts and Leisure, PRONI is responsible for ensuring that all of these organizations are aware of their legislative responsibilities in respect of their records and of the importance of setting up and maintaining appropriate records management systems. PRONI is also concerned with identifying any deficiencies in the way records are organized and maintained and in records management procedures generally. Specifically PRONI is involved in:

Agreeing retention periods for records contained in the Retention and Disposal Schedule

Updating the Disposal Schedule

Reviewing records

Storage of records PRONI’s role in reviewing records is confined to assessing their historical/research value. Public Records Act (Northern Ireland) 1923

The Public Records Act (NI) 1923 provides that certain records are public records under the charge and management of the Department of Culture, Arts and Leisure and as such, they cannot be disposed of without prior reference to PRONI. All PBNI records are public records under the terms of the 1923 Act. PBNI’s Director and senior managers are personally accountable for records management within the organization. They have a duty to make arrangements for safekeeping and correct disposal under the Disposal of Documents Order (Northern Ireland) 1925.

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Freedom of Information Act 2000

The Freedom of Information Act 2000 creates a statutory right of access by the public to all records held by public bodies (with some exemptions). In order for PBNI to meet its obligations under this Act it is vital that records are held so that they are easily retrievable. Environmental Information Regulations 2004

The Environmental Information Regulations create a statutory obligation to provide access (subject to some exemptions) to information on the environment held by public bodies. Data Protection Act 1998

The 1998 Data Protection Act places a statutory obligation on PBNI to protect the personal data which it holds. In relation to records management this means that PBNI must implement measures to:

Maintain the accuracy of records held

Protect the security of personal information

Control access to personal information and

Make arrangements for secure disposal once the record is no longer required.

Limitations (Northern Ireland) Order 1989

The Limitations (Northern Ireland) Order 1989 sets out the statutory provisions governing the time limit for bringing a claim against another organization. This means that records should be kept for as long as is necessary to facilitate the requirements of the Order. The main provisions of the Order are: The limitation period for a claim based on contract is 6 years (Article 4). This is the rationale behind keeping invoices etc for that length of time. The limitation period for a claim for personal injury caused by negligence is 3 years from the date of injury, or if later 3 years from the date of knowledge of the person injured (there are some cases where this time period can be extended).

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1.3 Roles and Responsibilities

This guidance and procedures are applicable to all staff employed or contracted with PBNI including seconded staff, temporary staff, agency staff, students or other individuals associated with the provision of PBNI’s services. It applies to both manual and electronic records. The Senior Management Team The Senior Management Team is accountable for their staff’s compliance with PBNI’s records management guidance and procedures throughout the organization, and has a duty to ensure that the arrangements for safekeeping and eventual disposal of PBNI’ records are adhered to. All Senior Managers are responsible for ensuring that their staff are aware of their personal responsibilities for record keeping. This includes the creation, use, storage, security, restricted use and disposal of records. Lead Senior Manager for Records Management function This Manager will be responsible for:

Reviewing the records management procedures for PBNI and reporting to the Board where necessary.

Endorsing records management systems appropriate to allow the effective and efficient discharge of functions while meeting the statutory duty of records management.

Records Officer The Records Officer will provide guidance and assistance to key staff in PBNI who will have responsibility for the day-to-day management of records in their own teams/departments. The Records Officer is responsible for the development of systems that facilitate the effective and appropriate management of information produced in and received by PBNI. It is also the responsibility of the Records Officer to:

Ensure that guidance exists regarding the statutory requirements laid down in the Disposal of Documents (Northern Ireland) Order 1925 (made under the Public Records Act (Northern Ireland) 1923 for the destruction and preservation of records) and that adherence to the guidance is monitored.

Provide updates to Senior Managers of compliance with records management legislation and guidance.

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Co-ordinate the development and maintenance of the organisation’s Disposal Schedules in liaison with key staff throughout PBNI.

Remind staff of their responsibility to destroy records in accordance with Disposal Schedules.

Give guidance to staff reviewing records to ensure consistency in the decisions made.

Maintain proper records management procedures to help ensure consistency in the management of records.

Monitor the effectiveness of the records management guidance and adherence to the guidance.

Arrange for the training and awareness of staff in records management.

Provide the central co-ordination point for all off-site storage of records.

Provide the single co-ordination point for liaison with PRONI.

Develop professional standards and liaise with colleagues with the PBNI to develop best practice.

Middle Managers (includes Area Managers)1 Middle managers (including Area Managers) throughout PBNI are responsible for effectively operating administrative systems in support of the work of the organisation. These staff include office managers and other department managers. Their purpose is to assist the Records Officer to ensure consistency and application of guidance in respect of corporate and operational records management objectives. Area Managers are responsible for the management of operational files in liaison with Office Managers. In particular middle managers will be responsible for:

Liaising with the Records Officer to develop and maintain our Retention and Disposal Schedule

Provide advice to staff on records management procedures (including security and maintenance of records)

Maintaining team/department storage facilities

The creation of new files

Ensuring a file tracking sheet is completed when a file is removed from a filing cabinet

Closing manual files in line with this guidance

Closing electronic files in line with Organisational Guidance

1 Middle managers includes Area Managers (Operations), Staff Officers, Executive Officers (with line manager responsibilities) and Office Managers (Corporate)

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Ensuring that PBNI’s Retention and Disposal Schedule is used when disposing of manual files or deleting electronic files

Compliance with statutory and regulatory requirements

Individual Members of Staff

Every member of staff employed within PBNI is responsible for maintaining records in accordance with the PBNI’s Records Management Procedures. In particular they are responsible for:

Following the procedures for the creation of new files;

Applying PBNI’s Retention and Disposal Schedule and not retaining files beyond the specified periods;

Adhering to the Management of Information Policy and supporting guidance;

Adherence with the relevant information security and information assurance policies in respect of electronic records and the communication of information electronically;

Documenting and recording their work in accordance with PBNI’s Records Management Guidance;

Ensuring the integrity and security of all records while on PBNI premises or when being transported between PBNI premises or outside PBNI.

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2. Records Management Principles 2.1 What is a record?

The definition of a record is provided in the International Standard on Records

Management ISO 15489-1 2001 Part 1. It describes a record as:

“information created, received and maintained as evidence and information by an organisation or person, in pursuance of legal obligations or in the transaction of business” In the context of this guidance, a record is anything that is produced or received in the completion of an organizational activity and comprises content, context and structure sufficient to provide evidence of that activity. A document is information that is stored as a single unit on some medium (e.g. on paper, on a computer drive etc.). All documents are not official records. A business decision needs

to be taken with regard to each document as to whether it should be declared an official record. This decision should be taken by the author of the document, in consultation with their Manager if necessary. Documents held in any of the following formats could be records:

Paper documents

Audio tapes

DVD

Computer files

E-mails

Photographs

Forms

Within PBNI records can be split into two distinct headings:

a) Operational Records

These consist of records on offenders under the PBNI’s supervision (statutory and non-statutory), those who through a court order or direction are required to engage with PBNI, and those who engage voluntarily with PBNI. It also includes victims who have engaged with P BNI’s Victim Information Scheme. Offender files are stored separately and are subject to rigid internal and external standards (including gate-keeping procedures) that govern how offender information is held. In particular operational records should be managed in accordance with the PBNI’s Best Practice Framework (Standards) for all aspects of work undertaken with offenders under supervision. The instructions for maintenance of operational records are set out in section 3 of this guidance.

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b) Corporate Records

These are records that support the administrative functions of the organisation for example Finance, Human Resources, Communications and Statistics and Research. These records should be managed in accordance with the instructions set out in section 4 of this document.

2.2 Why do you need to keep records?

Records enable PBNI to:

Conduct our business in an orderly, efficient and accountable manner;

Deliver services in a consistent and equitable manner;

Support and document decision making;

Provide evidence of business activity;

Maintain corporate memory;

Provide continuity in the event of disaster;

Meet legislative and regulatory requirements; and

Protect the interests of our employees, clients and stakeholders. 2.3 What information must be recorded?

Registered files constitute the records of the organisation. Each file should make up a comprehensive record of what was done, how it was done and why and by whom. Files should also provide evidence of any actions and decisions that were rejected and why. Generally any item should be kept in a registered file that:

Contains information or work relating to a file subject;

Shows the reasons why something has been accepted or rejected or why something has been done or not done;

Shows who was involved in the decision making or work done;

Contains financial papers and statistics

Relates to the success or failure of any work or projected work associated with the file subject, or success or failure to meet targets, standards or other criteria;

Contains details of contact and supervision relating to the file subject.

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2.4 What information should not be recorded?

Ephemeral records are those records that have little or no business or evidential value to PBNI after a relatively short period (at most a few days). The following can be considered as ephemeral records and as such do not need to be held on a registered file:

Personal and social messages

Simple queries, such as requests for copies of documents

Messages about meetings etc.

Exact copies of records retained on registered files. 2.5 The Importance of Good Filing Practice

Good filing practices will ensure efficient, prompt and reliable retrieval of information and will facilitate the segregation of short-term records from records of long-term value. Short-term records can be automatically destroyed after the agreed retention period. Please see PBNI’s Retention and Disposal Schedule for further information. In order to achieve these objectives and also ensure that PBNI complies fully with its statutory obligations under the Public Records Act 1923, it is essential that files are properly managed from their first creation through to their eventual destruction or preservation. Good file management will be greatly assisted if an accurate record is maintained of all files held within an office. This will also help avoid unnecessary creation of new records where existing files/records exist. 2.6 Storage Methods for manual information The following systems of filing are in use in PBNI:

Vertical Filing Vertical storage of files in two, four and five drawer cabinets is perhaps the most common way of storing files. The benefits of this system are that the storage is neat, the records are protected from dust and the cabinets are usually lockable making the storage secure. However this method may be inefficient when dealing with large numbers of files.

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Lateral Filing Lateral filing is considered to be the most efficient and inexpensive way of storing files. The files are stored lengthways along their spine and held upright by guide plates fitted to the shelves. This storage also allows for fast retrieval of files and can be used by more than one person.

Suspended Systems In these types of systems the files are stored in pockets, or envelopes, and suspended from rails fitted into the cabinets. This does provide for tidy storage, however there are a number of drawbacks: the provision of pockets and rails leads to an increase in costs and there is a reduction in storage space due to these items. They can also be time consuming to set up and awkward to re-arrange. 2.7 What happens if we don’t manage our records?

If PBNI does not adopt the systematic management of all of our information the organisation will not be complying with its legislative responsibilities. There are also security risks with an unmanaged system.

Current legislation means that public authorities such as PBNI have statutory obligations which will be fulfilled by having and maintaining an effective records management system. Requests for information governed by statutory response timescales will be very difficult to service if all records are not properly organised and retrievable. An unmanaged records system makes the performance of staff duties more difficult, costs the organisation in time, and resources and makes PBNI vulnerable to security breach, prosecution and reputational damage.

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3. Security of Records This section deals with security of records insofar as it relates to the use, storage and disposal of PBNI information. All staff are responsible for ensuring that

records, especially those that contain personal or restricted information, are held and managed securely. This is one of the 8 Data Protection Principles and failure to comply may result in a breach of the Data Protection Act 1998.

Staff should be aware of a number of high level information security breaches which have been publicised recently. It is vital that everyone takes responsibility for ensuring that information is always held in a secure manner appropriate to the protective marking and/or sensitivity of the information. This is particularly important when transporting information from one site to another. Senior and Middle Managers who manage or supervise staff are responsible for making sure their staff are aware of the importance of the security of their records. Each member of staff is responsible for reporting any breach or suspected breach of security to their manager.

This section should be read in conjunction with the suite of Information Security policies and procedures. These are held on the IT section on the PBNI Intranet under ‘Information Management Awareness’. They are:

Data Loss Incident Response Plan

Identification Card procedures

Information Security Awareness Overview

Information Assurance Policy

Information Security Procedures

Internet & Email Usage Policy

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Internet & Email Usage Procedures

Monitoring at Work procedures

PBNI Guidance Note – New Government Protective Marking Scheme

3.1 Sensitive/Protectively marked Information PBNI has a corporate responsibility to maintain the security of personal information. Its employees, temporary staff, students and contractors have individual responsibility in this regard. 3.2 Protective Markings The protective marking system has been developed to protect sensitive information in Public Bodies. Each level of protective marking corresponds to a standard of protection. The higher the level of marking attached to a document the greater the damage likely to occur if it is compromised. Information that does not carry a protective marking is deemed to be ‘nor protectively marked’ and would generally be accessible to all staff. Offender information in PBNI is protectively marked as ‘Official - Sensitive’. Please see the Guidance Note on the New Government Protective Marking Scheme held on the PBNI intranet for further information on Protective Marking. Links to this and to related policies can be found in the introduction to Section 3 of this document. 3.3 Security Measures Manual records which are protectively marked must be stored securely. The following security measures should be adhered to: Office Security

Manual records with protective markings must be stored in lockable filing cabinets.

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Filing cabinets holding protectively marked information must be locked when not in use or when the room is left unattended.

Information which contains a marking higher than ‘restricted’ must be stored in a fireproof lockable filing cabinet.

Copies of keys for all rooms and of filing cabinets storing records must be kept in a secure location.

Staff should adhere to a clear desk policy. When files are made available

on unattended desks material could be removed from them and copied or stolen. To ensure that our information is controlled and safe staff should ensure files with a protective marking are removed from desks when the member of staff responsible for the file is leaving for the day and returned to their designated secure storage.

Staff with responsibility for office buildings should ensure that the “closing routine”2 is followed at the end of each day.

Area/Office Managers should regularly monitor office security, checking offices, storage area for adherence to procedures and recording findings where necessary.

Posting/Transferring/Transporting Manual Records All post (except for routes covered internal courier provision) will be delivered by Royal Mail. All post should be marked with the full postal address and either First or Second Class post, Special Delivery or Recorded Delivery. It is important that staff ensure that any post containing sensitive or personal information of employees or clients is sent using Special Delivery only and the following procedure followed:

Personal or sensitive information should be double-enveloped with the inner envelope protectively marked as Restricted or Protect-Personal (depending on the nature of the information.) The envelopes should

2 The closing routine should include:

Checking and turning off any heaters, lights or other electrical equipment (computers should be

shut down by users and switched off using the push button on the hard drive unless otherwise

advised by IT for maintenance purposes).

Checking and ensuring all windows are closed and secure

Checking that all internal doors are closed (not locked) to help prevent the spread of fire.

Checking all staff and offenders have left the site to prevent “lock ins”.

Ensuring the exit door is closed and intruder alarm system is set when leaving. This should include

waiting for the exit tone to cease before leaving the door vicinity. If the tone does not stop staff

need to go back into the office and resolve any problems and set again.

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always have a return address to ensure, if undelivered, they can be returned to PBNI.

Special delivery ensures that the item can be tracked online and there is

electronic proof of delivery. Please note that Royal Mail’s large Special Delivery pouches can be obtained free of charge from the Royal Mail website for use when several delivery items are destined for the same address.

Recorded delivery gives proof of posting and signature on delivery. The

item that is posted is not tracked. Recorded delivery can be used if posting non personal or sensitive information but staff believe it is important to get the information signed for.

Staff should consider whether some information could be sent electronically rather than by post. Sensitive or personal information can only be sent electronically to an approved secure email address i.e. GSI. Further information can be found in the Internet and Email usage policy that can be found in the IT section on the PBNI intranet.

Protectively marked documents or files should not be removed from the office by PBNI staff without prior approval from an Area Manager.

There may be occasions when staff members are required to remove protectively marked information from the security of the office to meeting locations, court or to offender’s homes. It is essential that staff remove only what you think you will need for the meeting or visit.

Be especially vigilant when you are in transit. Keep items with you at all times. Particular risks to be avoided are leaving your briefcase or laptop unattended in a cloakroom, train luggage rack or a vehicle. Secure briefcases with a combination code have been issued by the IT department and these should be used where possible.

If transporting protectively marked documents by car or public transport you must not leave items unattended at any time. If you are travelling on public transport you must be careful not to read protectively marked material where it might be overseen. You are responsible for the safety of this information so ensure that it is protected.

No staff member should be working from home without prior approval of his or her Line Manager. If protectively marked documents or files containing personal data are needed for home-working then approval should only be given in exceptional circumstances and may require approval from a Deputy Director. Client information must not be worked on

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or stored on non-PBNI owned PCs and must not be emailed outside the PBNI network, including to or from a home or personal email account.

All protectively marked documents or files being moved from one location to another by a member of staff must remain in their possession at all times.

Faxing Information If faxing sensitive/protectively marked information staff must:

Consider whether sending the information by a means other than fax is more appropriate, such as using a courier service or secure email.

Make sure you double check the fax number you are using. It is best to dial from a directory of previously verified numbers.

Check you are sending a fax to a recipient with adequate security measures in place i.e. your fax should not be left uncollected in an open plan office.

As the recipient to confirm they are at the fax machine, they are ready to receive the document, and there is sufficient paper in the machine.

Ring up or email to confirm that that whole document has been received safely.

Use a cover sheet. This will let anyone know who the information is for and whether it is confidential or sensitive, without them having to look at the contents.

Additional Comments When handling any official documents outside the office you should, where possible, observe the following:

Keep personal and official matters safe and place protectively marked

material in appropriate files or folders.

Ensure that unauthorised people do not see protectively marked documents.

You should return all relevant protectively marked or sensitive waste to the office for destruction by placing it in the consoles provided. Disks, laptops or PCs provided by the office holding protectively marked data must be disposed of securely.

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3.4 Security of Electronic Records

All staff must adhere to the relevant Information Security and Information Assurance policies that can be found on the PBNI Intranet. Breach of these policies (with or without intent) could result in disciplinary action. Please see the links to the suite of PBNI security polices and guidance in the introduction to Section 6. 3.5 Secure Destruction of Records Records should only be destroyed once the review procedures have been carried out as set out in the PBNI’s Retention and Disposal Schedule. All manual records, including those with a protective marking should be destroyed in accordance with the guidance provided by Accommodation and Supplies e.g.:

All protectively marked waste must be placed in the locked consoles

currently provided by the shredding provider. No other documents should be placed there and they are not to be used as waste paper bins. These consoles are held in each PBNI office. A schedule for collection of the waste in these consoles is agreed with the relevant Office Manager liaising with staff from the shredding provider. At each visit staff from the shredding provider will unlock the console and shred the waste by using cross-shredders that are held in the shredding provider’s lorries that are parked outside the relevant PBNI office. The shredding provider’s staff then provide PBNI staff with a certificate to show how much material was shredded, the date the shredding took place, and the personnel involved. Where it is possible, a member of PBNI staff should observe this exercise. This is particularly important when there are a large number of offender files being shredded annually after the review by the Public Record Office for Northern Ireland. Staff should note that all protectively marked waste placed in a console from the shredding provider remains the property of PBNI until it is fully shredded by the cross-shredders in the shredding provider’s lorries.

Unclassified information that you may still regard as being ‘sensitive’ in

nature and content should placed in the shredding provider’s console.

Other unclassified information should be placed in the correct recycling bin. These are provided by the Accommodation and Supplies department.

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4. Operational Records Management Procedures

4.1 Operational Records PBNI’s operational records are largely held in an electronic records management system PIMS (Probation Information Management System). PIMS has the capability to manage all case generated offender information within PBNI. Usage of PIMS is monitored and staff should note that unauthorised or improper use of PIMS may result in disciplinary and/or criminal action.

Offender files whether manual or electronic, must be maintained in accordance with current Northern Ireland Standards relating to the Management of

Offenders and disposed of in accordance with the Retention and Disposal Schedule. 4.2 Operational Records held on PIMS

4.2.1 Probation Information Management System (PIMS) PIMS manages all PBNI generated case management information electronically in a centralised and structured database. Offender files held electronically are recognised as a formal electronic record. Only records on offenders not held on PIMS, or records which need a signature for authenticity should be held on any accompanying manual file, and information should not be duplicated. The following section sets out some guidelines on the management of PIMS electronic records. For more detailed guidance please consult your PIMS training manual or contact the PIMS implementation team. 4.2.2 Creation of PIMS record

PIMS is PBNI’s case management system; therefore an electronic record should be created on all PBNI clients and referrals. A referral is a request for some PBNI intervention – e.g., request for PSR from court. A client can have more than one referral.

4.2.3 Titling

As PIMS provides a unique client number and referral number, there is no need to title the record.

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4.2.4 Content

All recorded aspects of managing a case should be done electronically using PIMS. Records relating to clients will include client details, standard letters and

risk assessments. Referrals will include any court outcomes, Order details and reports.

4.2.5 Filing/Storage

All data input on PIMS is held on the PIMS server. Some paper records still exist (e.g., signed documents, court order and external correspondence). There should rarely be any need to copy any part of the electronic record to a manual file, except where the document requires the signature of the client. The PIMS paper file is dealt with at 3.3.1. 4.2.6 Auditing and monitoring All middle and senior managers are responsible for monitoring staff performance against standards. Various audit trails exist within PIMS that detail creation, update and deletion of data. Staffs have different levels of access to these audit trails, according to their status on PIMS. There is a need for data validation and all operational staff has a role in this. This is in keeping with Data Protection Principles, where personal information is required to be accurate and kept up to date. When found, data inaccuracies should be corrected immediately. All staff must also note that unauthorised or improper use of PIMS may result in disciplinary and/or criminal action. 4.2.7 Scanning on Documents to PIMS A risk assessment was conducted on scanning documents and it was agreed that it is PBNI’s preferred practice to scan relevant documents onto PIMS as opposed to keeping paper copies. Staff must ensure that they have successfully scanned on notes, papers and documents before disposing of paper copies. See the Guidance for scanning Documents before attaching to PIMS at Appendix 14.

4.2.8 Closing and Disposal

Please refer to 3.4

4.3 Manual Operational Records

PIMs manual records are manual operational case records that should only contain relevant paper records relating to the client which have been generated externally or which have to be signed by the client. (The creation of the PIMS manual record is dictated solely by the generation of the electronic record on PIMS.)

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4.3.1 Titling The label at Appendix 4 should be completed and placed on the front cover of the PIMS manual record. This information will correspond to the information on PIMS. 4.3.2 Content

The PIMS manual record should not contain copies of any information held on PIMS unless it requires a signature. It should not contain duplicate information

already held on PIMS. Although the content of a PIMS manual record may differ depending on the

nature of the court disposal, by and large the content should include the following:

Statutory Order Court Summary/result with reporting instructions

Monitoring forms (linked to NI Standards) - this is for probation staff not

clients Referrals to external projects Other correspondence e.g. letters from doctor

Record of home leave

Worksheets (Community Service) Work Plans (which have to be signed)

The Criminal Record should not be held manually at all. In certain circumstances

it may be necessary to print the criminal record for a specific purpose, for example a pre-sentence report interview. When this information has been used, the print out of the criminal record should be disposed of immediately and

securely in a console from the company that provides shredding services for PBNI.

4.3.3 Handwritten Notes for Pre-Sentence Reports All handwritten notes relating to the preparation of pre-sentence reports are discoverable either by the Courts and/or to meet the requirements of the Data Protection Act. All such notes must be legible, relevant and dated with the author’s name included. Notes should only be recorded on blank sheets of A4 paper or on a blank ACE form. Handwritten notes should be retained in accordance with PBNI’s Retention and Disposal Schedule. Please see Appendix 13.

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4.3.4 Storage of Manual Operational Records Manual operational records relating to orders are stored primarily in lockable filing cabinets at each Probation Office. In order to ensure easy retrieval it is essential that manual operational records be held in a structured system. Case records must be stored in the following way:

Current Statutory Supervision cases (blue file covers)

Held in alphabetical order by the surname of the Offender

Closed Statutory Supervision cases (blue file covers, then placed in

envelopes when file is closed at the end of the Probation Order)

Held in year order using the year the Probation Order ended or

the last action taken, Then by alphabetical order by the surname of the Offender.

4.3.5 Storage of High Risk Operational Records

Current Statutory/ Non-statutory Supervision Schedule 1 Sex Offenders cases, (red file covers)

Held in year order using the year the Probation Order ended or the

last action taken Held in alphabetical order by the surname of the Offender.

Closed Statutory/Non-statutory Supervision Schedule 1 Sex Offenders cases (red file covers, then placed in envelopes when file is closed at the end of the Probation Order)

Held in year order using the year the Probation Order ended or

the last action taken, Then in alphabetical order by the surname of the Offender.

Current Risk of Serious Harm (RoSH)Cases, Life Sentence Cases or cases where there are Public Protection/Child Protection issues (yellow file covers)

Held in year order using the year the Probation Order ended or the last action taken,

Held in alphabetical order by the surname of the Offender.

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Closed Risk of Serious Harm (ROSH) Cases, Life Sentence Cases or

cases where there are Public Protection/Child Protection issues (yellow file covers, then placed in envelopes when file is closed at the end of the Probation Order.

These files are then held for 99 years from the date of closure.

Files which are closed with no further work anticipated should be earmarked for removal off-site by the relevant Area Manager and the Records Officer must be notified to arrange removal. These closed files should remain in offices for no longer than 12 months after the file is closed. After that time, Files should then be removed to PBNI’s off-site storage facility. In the interim, these files must continue to be held in secure, locked filing cabinets in the relevant office. For operational purposes, files may need to be held in outer offices for longer than 12 months.

Area Managers should take this decision and inform the Records Officer accordingly of their decision.

4.3.6 Tracking Current Manual Operational Records The Probation Officer who is responsible for the supervision of the offender generally holds their current Operational File. These files are usually held in a filing cabinet in the supervising Probation Officer’s office for the duration of the Probation Order. When the files are held in their office, the Probation Officer is responsible for their security and maintenance for the duration of the supervision period. A File Tracking Sheet is attached at Appendix 1. Each offender file must have this sheet and it should be completed when the file is removed from the filing cabinet by the person who is removing the file. The sheet should be placed in the filing slot when the file is removed from the filing cabinet for a significant period of time. On returning the file you should note the “date of return” on the tracking sheet. The tracking sheet should then be placed in the slot in front of the file for next use. This will ensure that the files can always be traced and should minimize the risk of a file being lost. 4.3.7 Tracking Closed Manual Operational Records The File Tracking Sheet should be completed when a closed offender file is removed from the filing cabinet. On returning the file you should note the “date of return” on the tracking sheet. This will ensure that the files can always be traced and should minimize the risk of a file being lost.

Middle Managers should ensure that all their staff are made aware of

the need to complete tracking sheets when removing and returning

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files from the filing cabinet. This is particularly important if files are removed temporarily from the office. 4.4 Closing and Disposal arrangements for operational records This section deals with the closing and disposal arrangements in respect of:

The operational records held on PIMS electronically

The PIMS Manual Record and

Manual operational records

Apart from some minor differences in respect of the documentation for manual operational records, the procedures to be followed are the same for all three types of records. 4.4.1 Closing Operational records (manual and electronic) should be closed when PBNI’s involvement with a service user has reached an end. In most cases this will be where an order has been completed or when a non-PBNI sentence has been given after the completion of the PSR. Where there is outstanding or future work anticipated on a case, the file should not be closed. Office Managers must consult with relevant area managers before a decision to destroy a file is made.

When an Order ends it is the Supervising Officer’s responsibility to ensure that the information within the referral is complete and up to date. At this point the Supervising Officer requests closure (by clicking on the ‘Closure Request’ button) and the referral is removed from their current referral list. The Area Manager is automatically notified by e mail and will monitor the electronic and manual record and decide whether to accept or reject closure. Once accepted the referral closes. The referral can still be searched for and viewed and, if necessary, can be re-opened at a future date. When a manual operational record is closed, the details of the case must be noted on the Closed Files spreadsheet (Appendix 2) held in each office. This spreadsheet will include the date of the end of the Probation Order. All operational files need to be included on this spreadsheet, including those files that will not be eligible for review by PRONI for 99 years. In the case of Statutory Supervision case files this date is needed to calculate the correct disposal date. Once closed, the files should be removed from their original plastic covers and placed into envelopes. These envelopes should be labelled as detailed at Appendix 4.

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Closed Sex Offender, Schedule 1, RoSH or Life Sentence Cases should be moved to PBNI’s current off-site storage facility after a period of one year. If after this period there is still anticipation of further work on the file, the operational manager should contact the Records Officer stating that this is the case and agreeing a date for this to be reviewed. Details of the process of sending files to the off-site storage facility are set out in Appendix 11. All files earmarked for removal to the off-site storage facility need to be listed in the closed file spreadsheet set out in Appendix 2 - Closed File Spreadsheet before being sent to the off-site storage facility. 4.4.2 Disposal Arrangements Before an operational file is closed (be it manual or electronic), the Retention and Disposal Schedule must be consulted and direction taken from it as to the retention period for that file.

Staff must ensure that any record disposed of is done so in accordance with the schedule. The final action column of the schedule determines how that record will be disposed. There are 4 options for final action:

Determined upon Review

Relevant Manager authorises destruction

Permanent Preservation

Destroy/Delete 4.4.3 Determined upon review Operational case files (manual or electronic) must not be destroyed (or deleted

from PIMS), unless authorised by the Records Officer, as PRONI will review all relevant operational files or a selection of these files from any location on an annual basis. The purpose of the review process is to identify and select records of continuing value from records that can be destroyed. The timing of the review and files to be reviewed will be agreed between the Records Officer and representatives from PRONI. PRONI Review Operational records identified by the Retention and Disposal Schedule to be “determined upon review “will be subject to a PRONI review. The Records Officer and PRONI staff will agree the size and type of sample of case files for review on an annual basis. This review will determine the files which can be disposed of, and which files must be held by PBNI for Second Review (i.e. a further 15 years). The files selected for second review will be held by PBNI for this period of time.

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To facilitate the review by PRONI, the Area Manager must review all offender files and notify the Office Manager of the outcome of this review process. The Office Manager will liaise with the Records Officer and arrange for the files to be reviewed, to be collected from offices before the first working day of February, or as close to this date as possible.

4.4.4 Relevant Manager authorises destruction

Where the Retention and Disposal Schedule states that “relevant managers authorises destruction” these operational records (not case files – these are either reviewed by PRONI or dealt with as at 3.4.1 and 3.4.3) are to be assessed by the appropriate manager to determine whether or not the records should be retained for a further period. The purpose of this process is to identify and select records of continuing value from records that can be destroyed.

After records have been closed they may continue to be of value for two main reasons:

1. Business value – they provide the organisation with valuable source of reference with regards to its operations, relationships or environment.

2. Archival Value – they provide a resource for historical research to a wide

range of future uses. In assessing the value of records at first review, the relevant manager should ask the following questions3:

Is there a continuing need to retain this record for the conduct of daily business?

How real is the need for constant reference to this record in the future?

Will it be needed to deal with enquiries in the future?

How many enquiries are likely?

Is the information needed for statistical analysis within the organisation?

Is the information required for conducting legal proceedings in the event of legal action being taken by, or against, PBNI?

Is there a legal requirement to retain these records?

Is there a financial need to retain these records (e.g. audit purposes)?

Is the information otherwise available, either within PBNI or elsewhere, or in published form?

If the reviewer, after checking that the file is not identified on the Retention and Disposal Schedule as part of a classification to be either “Determined Upon Review” and therefore reviewed by PRONI or permanently preserved can then decide that the file should be:

3 Extract from PRONI NIRMS 4 Reviewing Procedures March 2005

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Destroyed (where the file has no further value).

Retained.

The reviewer should complete a standard first review form (Appendix 6) and the decision should be documented on the Closed File Spreadsheet (Appendix 2). If the reviewer recommends a file for retention it will be retained by PBNI until it is due for Second Review (i.e. after a further 15 years). During the second review the Records Officer along with staff from PRONI will select files for permanent preservation or destruction. The reason for this decision (to preserve or destroy) must be clearly stated on a Second Review form (Appendix 8). The Records Officer will notify the relevant Manager of the outcome of this process and ask them to update the Closed File Spreadsheet (Appendix 3) accordingly. Files that are selected for permanent preservation are to be transferred to PRONI.

4.4.5 Permanent Preservation Case files are retained to “enable certain broad conclusions as to historical, economic or social trends to be drawn”4 therefore only a sample of case files are selected for permanent preservation. When selecting case files through the review process for permanent preservation, PRONI will consider the files that will:

Help to promote interest in the history of the individual, of a community or of society in Northern Ireland as whole

Be of direct value to education organisations

Reflect social diversity5 4.4.6 Destroy Operational records identified by the PBNI’s Retention and Disposal Schedule to be “destroy(ed)” can be disposed of without review, after the stated retention period. This is because they have no continuing business/legal value and are of no historical or research value to PRONI.

4 Committee on Departmental Records Report (1954) Cmd 9163 or Grigg Committee (para62) 5 Criteria extracted from National Archives “Operational Selection Policy OSP0 The Selection of Case

Files: Sampling Techniques” October 2005

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5. Corporate Records Management Procedures 5.1 Corporate Records

Corporate records cover information about the running of the organisation and corporate governance issues. This area supports the operational process, and includes departments such as Human Resources, Finance, Communications and Statistics and Research. These records are vital to the facilitation of the smooth running of the organisation. 5.2 File Creation

A reliable record is one whose contents can be trusted as a full and accurate representation of the transactions of the organisation and can be depended upon to provide evidence of subsequent transactions or activities. Records should be created at the time of the transaction or incident to which they relate, or soon afterwards, by staff members who have direct knowledge of the facts. 5.3 Registration of Records Registration is a system which allocates a unique identifier (numerical and alphabetical prefix) to each record and which annotates that sequentially in a “register”. The purpose of registration is to provide evidence that an official record has been created or captured in a record-keeping system. As all the records held within a Public Body constitute the collective memory of that Body, it is important that all records relating to the work of the organisation are kept in registered files rather than being held on ‘personal’ files or folders of staff. Determining which records require registration is an important decision and when deciding the information to hold in a registered file staff must consider the organisation’s requirements to maintain accountable records of particular business activities and its information needs. See section 2.3. All offices hold a certain amount of the same kind of information, including reference information. Each office also holds an Accident Log Book and a Fire Log Book that are issued by and returned to the Health and Safety Officer. These should not be included on the File Register.

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5.3.1 The Register Within each department or office there should be a central Register where individuals can log the details of new files opened. The Register at Appendix 5 should be used for this purpose. This Register should be held electronically on the department’s or office’s team drive. Before creating a new registered file, the register should be checked to see if an existing file could be used to file your documents. Once it becomes clear that a new file is required a registration number (see 4.3.2) should be recorded against the file name and should be noted on the spreadsheet. The document or information should be placed inside a standard PBNI file cover (See 4.3.4) and stored in the relevant filing system (see 4.7). Office Managers or relevant managers in corporate teams should monitor the File Register (Appendix 5) of the offices they are responsible for, to ensure that the Register is being completed, kept up to date and is being used correctly. The following details of the new file(s) should be recorded on this register:

the file registration number,

file title,

the date that the file was opened When registering a file the following points must be adhered to:

The registration number assigned to each file must be unique. (See 4.3.2)

The file title must be unique. (See 4.3.3)

The title and reference identity must be unique and easily understood by all users.

Details should be clearly noted on the file cover. (See 4.3.4)

It is important that all files are readily identifiable in order to facilitate checking against PBNI’s Retention & Disposal Schedule so that the correct destruction or preservation action is applied. 5.3.2 Registering and Referencing Files

When a new corporate file is opened it must be registered and given a unique reference. The file reference is made up of four elements.

1st element - This should indicate the department or office to which the record belongs. A list of prefixes covering all PBNI offices/departments is attached at Appendix 10. This prefix will remain the same even though the department may have a change of name.

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2nd element – This should be the title of the file (see titling at 4.3.3). 3rd element – This number indicates the number of files that have opened within that work area. 4th element – Year file opened

Therefore: 1st element = the department / office code 2nd element= the title 3rd element = the volume number 4th element = Year For example: Department = Human Resources Title = Recruitment of AOT staff Volume number = 1 Year file opened= 2010 The unique reference would then read as HR/Recruitment of AOT staff/1/2010

Field teams in PBNI (i.e. those teams that are based outside HQ) generally hold a small amount of administrative information that needs to be held as an official record. This information should be registered using the location code relevant to the office that is at Appendix 10 in the same format as above. The list of registered files should be maintained centrally at each department in HQ and in each field team office. These files should then be held in alphabetical order by the title of the file (e.g. Recruitment of AOT staff) and stored in a filing cabinet or cupboard. 5.3.3 File Titles A successful filing system is dependent on a satisfactory standard of file titling. The following are key considerations:

The title of every file should be accurate and fully reflect the content.

It should be brief but comprehensive enough to describe the contents accurately – remember it is not always the person who opened the file who will be searching for it.

The title should reflect the main subject area to which the papers refer.

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The title needs to be carefully considered or it is probable that the filing system will become unreliable and untrustworthy. If titles are inaccurate, ambiguous or imprecise then retrieval of information will be difficult, staff time will be wasted and eventually staff will lose confidence in the system, resulting in an increase in the number of duplicate and unregistered files created as well as loss of information. AVOID:

Abbreviations/acronyms

Vagueness e.g. terms such as Miscellaneous or General

Imprecision e.g. Staff, Finance

Abstractions e.g. Good Practice

File titles should not use the word ‘The’ or ‘A’ at the beginning

Corporate Files should not be named after an individual member of staff.

5.3.4 Corporate File Covers

Corporate records should be held in PBNI File Covers6. These file covers have spaces allocated for the following information:

Reg No (the unique identifier):

Space for Title or label with title on it Papers from Year:

Former File No: Year of first paper:

Year of last paper:

First Review: Second Review:

On opening a file you will be required to fill in the File Registration, File Title and Year File opened. On closing a file (see section 4.9) you will be required to fill in the Year File closed and Date of first review. This date can be obtained by consulting the Retention and Disposal Schedule. The Records Officer will complete the date of second review and the date file passed to PRONI, if applicable. 5.4 Contents of a Registered File The following are examples of the type of administrative information that should be kept and filed. This list is not exhaustive and includes:

6 The Records Officer will organise an initial supply of printed file covers for all offices. Thereafter

each office must order future supplies from Accommodation & Supplies.

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Relevant correspondence

Minutes of meetings (one copy per team/office)

Staffing Issues

Bids for contracts

Copies of accounts

Financial statements

Statistical records

Draft papers issued for comment together with comments received

Final documents Currently, the majority of corporate records are paper records. However, information that might be considered a record might be received or created in other formats e.g. by phone, fax or e-mail. The author of the information must determine, (if need be in consultation with their Manager), whether the information needs to be kept as a record on the registered file. Please also see section 2.3. Where information has to be filed, it must be printed or written out in “hard copy”. This information should be clearly signed and dated if appropriate. It is important to distinguish between ‘working papers’ and those documents that need to be filed as an official record. It is equally important to remember not to hold information unnecessarily. See section 2.4. Examples of items that should not be kept in a registered file are:

Copies of minutes and papers sent for information only (the originator of the minutes and papers should place a copy on a registered file and all other recipients should hold them as working papers only)

Papers that have been filed in another file or department/team

Papers that are not relevant to your department/office 5.5 Filing

All PBNI staff regardless of grade has a responsibility to ensure that all records are filed in date order in the appropriate files. The person who initiates the creation of a document is responsible for filing it or ensuring it is filed. Please note box files are not suitable for holding registered PBNI records. They may be used for holding working papers but records must be placed on a registered file with an appropriate file cover.

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5.5.1 Practical Points for Manual Filing

There are some practical points worth noting in relation to good records management practice.

Paper clips and pins should be removed from papers before filing, as these will damage the paper and when rusted can be a health hazard.

Flags, either adhesive tabs or strips of paper attached to a page with sellotape should be avoided – instead use card dividers.

File covers should provide adequate protection for the papers and preferably have a flap that should be used to prevent papers from becoming dog-eared. If they become tatty or torn, new covers should be prepared and the front of the old covers retained inside the new ones. Old covers form part of the original record.

Files should not be filled too full – they should not be more than 25mm (one inch) thick. Bulky files should be closed and a continuation file opened and cross-referenced with the old part of the file.

Files should not contain any loose papers or post-its.

Do not use metal tags – instead use plastic ended tags.

Avoid the duplication of papers – only one copy of any piece of information should normally be filed on any one file.

Papers to be filed should be punched one inch in and one inch down from the edge to minimise the danger of detachment.

All papers received for filing should bear a file reference number indicating the location the document should be filed in.

Papers should be filed in date order with the most recent papers on top. This is very important as the review and access dates are calculated from the date of the last paper on the file and, if the latest document is not on the top, it is possible that the wrong terminal date will be assumed.

All papers should be filed on the right hand side of the file. Bulky or outsize items can be stored in a pocket or an envelope inside the cover on the left hand side.

Where papers relate to two or more files place a copy of the papers on each file with a note of the numbers of all other related files both on the papers and on the file covers.

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5.6 Arrangement of papers in Corporate Records It is important that papers within an administrative file are arranged in a system that allows for the fast retrieval of information. Papers should be filed in date order with the oldest at the bottom and the most recent papers on top. This is very important as the file review date is calculated from the date of the last paper filed. If the last paper is not on the top, the wrong review date will be calculated. Although the information in files should be in date order, where files contain information straddling several years and perhaps covering more than one subject area, you should ensure that the date of the last insert actually reflects the chronological order of the contents. All documents should be filed on the right hand side of the file. 5.7 Storage of Corporate Files Manual corporate files should be stored in the department / office in a central system of filing cabinets. In order to ensure easy access and retrieval and for security reasons it is essential that files are held in a structured system, in a filing cabinet which is locked when it is not in use. 5.8 Tracking Corporate Files A File Tracking Sheet is attached at Appendix 1. This should be completed and held in the filing slot when the file is removed from the cabinet and taken out of the office. On returning the file you should note the “date of return” on the tracking sheet and place it back in front of the file. This will ensure that the files can always be traced and should minimize the risk of a file being lost.

Middle Managers should ensure that staff are aware of this procedure i.e. the completion of tracking sheets for the removal of files from, and return of files to, the filing cabinet.

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5.9 Closing Corporate Files

All corporate files should be closed after five years. Corporate files can be closed at any time during the five years for any of the following reasons:

The file reaches 2.5 cm thick. In this event a new volume (Volume 2, then Volume 3 etc.) of the file should be opened. The new file should have the same title as the original and should be cross-referenced to the original.

The file subject is finished (e.g. the title is time bounded.)

Nothing new has been added for 2 years. Records should be closed as soon as they have ceased to be used for current work purposes although the information on these files may still be required for reference. In certain circumstances a file can be kept open for up to 10 years when it is determined that the administrative value is such that the file needs to be held, or in circumstances where it remains the only source of reference for a particular issue. This can only be authorised by the Office Manager in field teams, or the relevant Manager responsible for the business area in PBNI Headquarters. The reason for keeping the file open should be recorded on the front of the file. Once a file is closed no further papers should added. These should be placed on a new file, or volume, with adequate cross-reference. The relevant manager or delegated person should complete the closure box on the front of the file cover by inserting the date of the last paper, stamping or writing the word closed, and inserting a closure sheet (see Appendix 5) on the inside Right Hand Side (RHS) of the file The relevant manager or delegated person should also consult the disposal schedule and complete the front cover of the file, indicating the date on which the file should be reviewed and/ or destroyed. 5.10 Disposal Arrangements for Corporate Files PBNI’s Retention and Disposal Schedule outlines all records created by PBNI and the periods agreed for their retention. This provides PBNI with its legal basis for disposing of records. Staff must therefore ensure that any record disposed of is done so in accordance with the Schedule The final action column of the schedule determines how that record will be disposed of.

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There are 4 options for final action:

Determined upon Review

Relevant Manager authorises destruction

Permanent Preservation

Destroy 5.11 Determined upon Review

Corporate records identified by the Retention and Disposal Schedule to be “determined by the review process” will be subject to a review process by PRONI. These files should be brought to the attention of the Records Officer who will arrange for them to be reviewed by PRONI. PRONI will make a decision whether or not these files can be destroyed or should be held for a further 15 years. The files that PRONI identify for a second review in 15 years will be held at a central point identified by the Records Officer. The Records Officer will notify the relevant Manager of the outcome of this process and ask them to update their File Register (Appendix 4) accordingly. Files held for a further 15 years will be reviewed again by PRONI who will make a decision as to whether the file should be preserved permanently because of its historical or research value, or whether it should be destroyed. The Records Officer will notify the relevant Manager of the outcome of this process and ask them to update the File Register (Appendix 4) accordingly. Files selected for permanent preservation will then be transferred to PRONI. 5.12 Relevant Manager authorises destruction Where the Retention and Disposal Schedule states that “relevant managers authorises destruction” these corporate records will be assessed by the appropriate manager to determine whether or not the records should be retained for a further period. The purpose of this process is to identify and select records of continuing value from records that can be destroyed. After records have been closed they may continue to be of value for two main reasons:

1. Business value – they provide the organisation with valuable source of reference with regards to its operations, relationships or environment.

2. Archival Value – they provide a resource for historical research to a

wide range of future uses.

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In assessing the value of corporate records at first review, Office Managers or relevant managers should ask the following questions7:

Is there a continuing need to retain this record for the conduct of daily business?

How real is the need for constant reference to this record in the future?

Will it be needed to deal with enquiries in the future?

How many enquiries are likely?

Is the information needed for statistical analysis within the organisation?

Is the information required for conducting legal proceedings in the event of legal action being taken by, or against, PBNI?

Is there a legal requirement to retain these records?

Is there a financial need to retain these records (e.g. audit purposes)?

Is the information otherwise available, either within PBNI or elsewhere, or in published form?

The reviewer, after checking that the file is not identified on the Retention and Disposal Schedule as part of a classification to be either “Determined Upon Review” and therefore reviewed by PRONI or permanently preserved can then decide that the file should be:

Destroyed (where the file has no further administrative value).

Retained.

The reviewer should complete a standard first review form (Appendix 6) and the decision should be documented on the File Register (Appendix 4). If the reviewer recommends a file for retention it will be retained by PBNI until it is due for Second Review (i.e. after a further 15 years). During the second review the Records Officer along with staff from PRONI will select files for permanent preservation or destruction. The reason for this decision (to preserve or destroy) must be clearly stated on a Second Review form (Appendix 7). The Records Officer will notify the relevant Manager of the outcome of this process and ask them to update the File Register (Appendix 4) accordingly. Files that are selected for permanent preservation are to be transferred to PRONI and held there.

7 Extract from PRONI NIRMS 4 Reviewing Procedures March 2005

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5.13 Permanent Preservation

Certain groups of files and papers can be readily defined as worthy of selection for permanent preservation. PRONI has identified the records in the Retention and Disposal Schedule that require permanent preservation. Other records have been selected for review to give both PBNI and PRONI the chance to determine their usefulness. When identifying records through the review process for permanent preservation PBNI should look out for files that document:

Board decisions and actions

Major projects and initiatives undertaken by PBNI

Major changes in functions, policy and structure

Unique information gathered by PBNI

Information relating to the origins and history of PBNI

Copies of annual and other major reports produced by PBNI 5.14 Destroy Corporate records identified by the PBNI’s Retention and Disposal Schedule to be destroyed can be disposed of without review, after the stated retention period has ended. This is because they have no continuing business/legal value and are of no historical or research value to PRONI.

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6. Managing Electronic Documents in Microsoft Office As electronic methods of working increase it is important for staff to become familiar with consistent standards in practice regarding the management of electronic documents. Presently PBNI use Microsoft Office and MS Outlook on a local area network to create and store electronic documents. Microsoft Office and MS Outlook are not regarded as an EDRMS (Electronic Document Records Management System) as the information is held in an unstructured manner. For corporate electronic information to be part of a registered record it should be printed to paper and placed on a manual registered file, or held electronically in a structured team drive. This applies to business related material that has been declared an official record and not to all information and working papers that are held by staff (See Section 4.4). However, information held on a database is structured and therefore does not need to be printed and placed on a manual file. It is recognised that from a practical point of view staff will often hold information electronically that does not constitute a record and this information should be treated the same way as manual working papers and deleted without saving. To help facilitate the easy retrieval of documents, the following guidelines should be applied to electronic documents created in Microsoft Office. 6.1 Naming Conventions for Electronic Documents

This section is intended to provide a common set of rules to apply to the naming of electronic documents stored in Microsoft Office e.g. word-processed documents, spreadsheets and presentations. 'File names' are the names listed in the file directory, which are given to new electronic documents when created. The following good practice rules should be adhered to when naming electronic documents

Keep file names short, but meaningful.

Avoid using initials, abbreviations and codes that are not commonly understood.

You can use words that have standard abbreviations e.g. “cttee” (Which is a standard abbreviation for Committee)

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Do not use words like “the”, “a” and “and” as they do not contribute to the meaning of a topic, e.g. ”The Probation and Information Services Committee.doc” should be “ProbationInformationServicesCttee.doc”.

Avoid unnecessary repetition in electronic documents. Unnecessary repetition increases the length of file names and file paths. Do not repeat elements already in the folder title in which the document will be filed.

Use capital letters to set the limit of words, not spaces or underscores.

If using a date in the file name of an electronic document, state the date ‘back to front’. The YYYYMMDD (year, month, day) pattern should be applied to dates, as months spelt alphabetically do not file in chronological order. This means that the file title would look like this:

20160404 PIMS Training Schedule.doc

Giving the dates in this way means that the chronological order of the records is maintained when the file names are listed in the file directory. This helps when trying to retrieve the latest dated record and when disposing of records in accordance with the Retention and Disposal Schedule.

When including a personal name in a file name, give the surname first followed by the first name or initials. This might be a title of a file where the topic of the file relates to a specific individual. It is not appropriate to name records after the record owner or creator so staff should avoid naming records after themselves.

Avoid using a common word such as “letter” at the start of file names. If a common word is used at the start of a title, all of the records starting with this word will appear together in the file directory making it more difficult to retrieve the records you are looking for.

The file names of records relating to recurring events (e.g. meeting

minutes and papers, weekly, monthly or annual reports) should include the date and the event name or a description of the event and be short, to the point and easily recognisable.

Some documents go through a number of versions, for example they start out as working drafts and finish with a final draft, which may be reviewed and updated at a later date. It is important to be

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able to differentiate between these various drafts by giving them their own number.

Where a version number is applicable, it should always appear in the file name of the electronic document, so that the most recent version can be easily identified and retrieved. You should note that not all documents are modified in this manner (see 5.2 below). This will be applicable to policy documents, guidance and minutes, which tend to be modified a number of times.

For example <Document name> <Version number> <draft/final>

As in: Managing Electronic Documents – v0.4 – draft.doc 6.2 Version Control Business documents, proposals and policy documents and other documents are generally written and revised several times and may have a number of authors. Version control is a method of managing documents that are subject to redrafting, thereby enabling differences in authorship and content to be logged and controlled. It also allows the identification and retrieval of the most current version of a document. It is important that previous versions of these documents are not erroneously modified or deleted. Why is Version Control important?

Version control is important for documents that undergo a lot of revision and redrafting and is particularly important for electronic documents because they can be easily changed by a number of different users, and those changes may not be immediately apparent. Knowing which version is current is important for staff trying to find out which version of a policy is currently in force. Version control is also important for staff working on a collaborative document with a number of contributors and/or frequent revisions. An example of this might be a consultation response or a policy document. Version Control Techniques for PBNI

There are a number of techniques staff can use to version control their documents. These are described below in order of complexity starting with the most basic first.

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Most documents produced by staff in PBNI will only need the more basic techniques, such as placing a version number in the file name and in the header or footer of the document.

Basic Version Control

Staff should use a unique version number to distinguish one version from another. This procedure should be used where more than one version exists, or is likely to exist in the future. The version numbering system should use version numbers with points to reflect major and minor changes. For example using numbers 1,2,3 etc for major version changes and the decimal number for minor changes such as in: 0.1 first draft 0.2 second draft (following minor changes or amendments to first) 1.0 first document version given wider circulation 1.1 first document version amended to reflect changes after circulation 2.0 final draft Staff should include the version number at the end of the electronic document’s file name.

Document Control Sheet

Formal documents in PBNI, such as corporate reports and plans, Policies and Procedures, should use a Document Control Sheet (Appendix 9) to keep track of changes that have been made to a document, when, and by whom. This should

be placed after the title page. The version number should be placed on the document itself, in the header or footer text of each page and on the Document Control Sheet. It should also be

reflected in the file name. Once the document is completed it should be held in a registered file. If the

document is also to be held electronically, it should be saved and named appropriately so that it is clear that it is the final version and should not be changed.

Read-only tag It is possible to place a ‘Read-only tag’ on the final document to prevent any further changes from being made. To add a read-only tag to your electronic document follow the procedure below:

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Open Windows Explorer and navigate to your document. Right click on the document name and select “Properties”. On the “General” tab check the “Read-only box. Select “Apply” and then “OK”.

This reduces the likelihood of one version being overwritten. Use this procedure for finalised documents where the loss of the original would be a problem.

Naming Conventions for version control

Include the version number at the end of the document’s file name. The words ‘Draft’ or ‘Final’ should be added to the end of the file name to indicate the status of the version. The file name should be saved as a header or footer on the electronic version.

For example <Document name> <Version number> <draft/final> As in: 2008.04.01Managing Electronic Documents –0.4 – draft.doc

The file path to the document should be included in the footer of the electronic version. This sets out where the document is saved in the folder structure. An example of this would be: T:/ Compliance/Records Management/File Lists/2010Board Papers 6.3 Filing Electronic Documents

Standard folder titling should be developed for each department and team network drive. The department / team should agree standard folder titles. Teams might consider whether it is appropriate to mirror parts of the established paper filing structure when titling these standard folders. An example of the kind of folders teams/departments could create would be:

Contacts Complaints FOI/Data Protection request log Team Meetings Templates

These folders can then be divided into sub-folders. When an electronic document is created the member of staff responsible for the document should consider:

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1. Whether its contents require it to be printed to paper and placed in an appropriate registered file. See section 4.

2. Where to save it within the shared networked drive. Electronic documents

that are work related must be held in the shared Team drive in an appropriate folder or sub folder. They should not be saved in individuals’ personal drives e.g. “My documents”. This will ensure that it is readily accessible to other members of staff when the creator of the document is on leave, out of the office etc.

6.3.1 Holding Personal information electronically

Personal information should only be held in an individual’s personal drive e.g. “My documents” to ensure that only the member of staff who created the record can access it. This would include information which, although relating to PBNI is of a personal nature, such as Staff Appraisals, disciplinary matters etc and should only be held for a short period of time. Business information, even in draft form, must be held on the shared networked drive in the relevant folder. 6.4 Deleting Information Electronic information needs to be deleted in accordance with the Retention and Disposal Schedule. PBNI are legally bound to the retention and disposal periods specified in this Schedule and must adhere to these for their electronic records. Deleting records that are no longer required will also enable the computer network to run more effectively. 6.5 Managing Emails It is the responsibility of all staff that uses a PC to manage their e-mail accounts appropriately. This guidance should be read in conjunction with the Internet and E-mail Usage Policy and the Internet and E-mail Usage Monitoring Procedures and the Monitoring at Work policy. These are available on the PBNI Intranet. Housekeeping of e-mails must be carried out as a part of normal daily practice and not simply on an occasional basis.

It is important that e-mail messages are managed in order to:

Comply with Data Protection and Freedom of Information legislation.

Minimise the space and cost implications connected with the storage of e-mail, excessive retention of which can result in retrieval systems becoming inefficient.

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Enable the computer network to run more effectively.

Ensure that you can find what you want when you need it.

Ensure that your colleagues can find important information even if you are not in the office.

To manage e-mail messages appropriately, staff must identify and separate e-mail messages that are records of their business activities from routine, or ephemeral, e-mail messages. It is important that e-mail messages that need to be captured as records should be removed from an individual’s personal inbox and managed with other records that relate to that particular business activity.

When deciding whether an e-mail message constitutes a record, the context and content of the message must be considered. E-mail messages that need to be saved as a record are likely to contain information relating to or have value to the business transactions of PBNI. These e-mails need to be filed in the relevant paper based registered file. If you wish to keep an electronic copy of this information you should save the e-mail in the shared drive and not in Microsoft Outlook. Routine, personal or unimportant e-mail messages should be managed within the mailbox in Microsoft Office and kept only for as long as required before being deleted. These would include e-mail receipts, which should be sent to the deleted items folder immediately as should all ‘spam’ (unsolicited e-mail). Agendas for meetings or minutes and documents relating to meetings can be saved in the Calendar under the date of the event. By doing this all the papers needed for a meeting or event can be held in the one place.

Email attachments The basic rules for filing an e-mail message and attachments are:

The sender files a message sent within PBNI

The recipient files a message sent from outside the organisation

Recipients marked as c.c. do not need to file the message. The decision on whether it is necessary to save an e-mail and/or its attachment as a record depends on the context within which they were received.

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Attachments of important administrative value should be printed and placed on a registered file. If you also wish to save a copy of the information electronically you should save it in a shared network drive as a Microsoft Word document. The information should be filed with other documents relating to the same work area or subject. All E-mails/attachments that have an operational value should be saved by attaching the information to the PIMS system. Titling Sent/Received Emails When storing e-mails or their attachments electronically it is important for ease of retrieval that the titles accurately reflect the content. In most instances this will involve changing the title from that originally sent on the e-mail. Staff must follow these instructions when titling e-mails or attachments that are to be stored in a shared drive:

Change the title of the attachment when saving it to the Team/Shared drive if it does not accurately reflect the content of the attachment.

All instances of FW:(Forward) and RE:(Reference) should be removed from the title of an e-mail, as they do not provide any information about the content of the message.

Use abbreviations and acronyms with caution, as they may become obsolete over a period of time and can have more than one meaning.

Procedures for managing Emails It is important that all staff adhere to the following guidelines:

Allocate sufficient time each day to read through and action e-mail messages.

Use a folder to group e-mail messages of a similar nature or subject together.

Use the Out of Office Assistant Tool when you know you will be away from your desk for a lengthy period of time, so those sending e-mails will know when you are likely to return or expect a response.

Attachments or e-mails must only be held in Microsoft Outlook for a short time.

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Where possible attachments needed for a particular event e.g. meeting, can be saved into the electronic diary (as mentioned on page 37).

Attachments and e-mails that need to be held for longer periods of time should be managed as records. This involves printing them off and placing them on a registered file.

Delete e-mail messages that are kept elsewhere as records.

If a record is being moved from one office to another within a team use the T:(Team) drive to access the document. If it is being moved from one team to another team the information should be transferred within PBNI by e-mail. If you wish to move large folders of information you should contact the IT department for advice.

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7. Business Continuity

The need for business continuity is essential for a building where files/records are stored. PBNI need to be able to function effectively in circumstances where files/records are destroyed. Please see the PBNI Business Continuity Plan, the Risk Register and the IT Disaster Recovery Plan. Key points are: All Business Continuity planning should comprise three main elements:

PREVENTION – precautions to minimise the risk of a disaster taking place

PREPARATION – preparation you can make for the possibility of a disaster

REACTION/RECOVERY – action to be taken in the event of a disaster The following areas need to be considered:

Security

Fire

Flood Security

When not in use, keep records locked away and limit access to record stores and cabinets and to the keys for these storage facilities. Keys should be kept in a locked safe, or another secure compartment.

Have an effective tracking system that records the location of files,

whether in storage or on loan.

For electronic records it is important to guard against viruses and maintain up to date security programmes.

Fire

As far as possible all installations where records are stored should be

fireproof.

Prohibit smoking.

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Consider installing fire and smoke alarm systems in the record storage areas

Consider installing fire suppression systems or fire extinguishing equipment.

7.1 Risk Register PBNI has a Risk Management Policy and supporting Risk Register that lists all the identified risks and the results of their analysis and evaluation. Information on the status of the risk is also included. This Risk Register should be continuously updated and reviewed. The Deputy Director (Corporate Services) is currently responsible for the management of the Risk Register.

The Risk Register should identify the Vital Records within PBNI.

Vital Records are those business records:

without which PBNI could not continue to operate or without which PBNI could not re-establish its key functions following a disaster

that establish and protect the rights and interests of PBNI, its staff and other stakeholders

that are needed to operate and re-establish PBNI’s functions during, and immediately after, a disaster.

Vital records will include legal documentation - contracts and agreements; original minutes of Board meetings, personnel and payroll records. Where vital records are irreplaceable or only replaceable at excessive cost, they should be given the highest level of protection.

7.2 Storage Conditions

The following considerations must be taken into account when selecting an area for long-term storage: Light

Light damage is caused when the paper absorbs the energy it produces. This causes a chemical reaction within the paper itself that leads to deterioration such as fading of inks and colours. The damage caused by light can never be reversed. Due to the cumulative effect of the damage caused by light it is essential not only to reduce light levels, but also to cut down the time a file is exposed. Therefore storage of files in

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drawers or closed cabinets is strongly advised. Tubular fluorescent lighting is considered to be the best form of lighting to be used in record storage areas. Damp

Basements and other potentially damp environments are not recommended for storing documents. They are more likely to be a source of damp, which causes damage to the paper. There are two types of damage that can be caused by damp; the first is the corrosion of metals, such as metal paper clips and staples. This can cause staining and disintegration to the areas surrounding the attachments. The other type of damage is biological, i.e. mould and insect infestation. Heat As well as making sure that storage areas are not too damp, care has to be taken that they are not too warm/dry. If this is so the surrounding air has the moisture drained from it. This results in the paper becoming very dry, which makes it brittle and more likely to damage. Pests One of the biggest dangers to material in storage is that caused by pests. This is especially true in storage conditions that don’t have temperature/humidity equipment. Paper can be infested with insects usually associated with wood. Two of the most common insects are silverfish and booklice. They are common in areas of high humidity and feed on paper.

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APPENDIX 1

File Tracking Sheet

Name of Offender/Title/Number of File :_______________

FILE REMOVED BY:

DATE REMOVED:

DATE RETURNED:

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APPENDIX 2

OPERATIONAL CLOSED FILES SPREADSHEET (for Manual files only)

RESTRICTED (when complete)

REFERRAL NO:1

REFERRAL NO:2

FIRST NAME

SURNAME DOB ORDER TYPE

YEAR ORDER EXPIRES

DECISION AT REVIEW

SECOND REVIEW

MONTH DISPOSED

TRANSFERRED TO

COMMENTS

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APPENDIX 3 OFFENDER LABEL TEMPLATE The following information should be completed on a label and attached to all Manual Offender Files: NAME OF CLIENT: DATE OF BIRTH: TYPE OF ORDER: DATE ORDER MADE: DATE ORDER ENDED: DISPOSAL REVIEW DATE: DATE SENT TO PRONI (if applicable): These have been distributed to all Office Managers for use on all manual Offender Files.

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APPENDIX 4

Template File Register for recording registered Corporate Files

FILE REGISTRATION NUMBER:

FILE TITLE:

FILE OPENED BY:

DATE FILE OPENED:

DATE FILE CLOSED:

DATE OF FIRST REVIEW

ACTION AT FIRST REVIEW

DATE OF SECOND OF REVIEW

ACTION AT SECOND

REVIEW

COMMENTS

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APPENDIX 5

FILE CLOSURE SHEET

THIS FILE IS CLOSED.

NO FURTHER PAPERS ARE TO BE ADDED.

A new file:

(a) has been opened (Ref. )* (b) will be opened on request *

* Delete as applicable

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APPENDIX 6

FIRST REVIEW FORM FOR CORPORATE FILES

(This form should be completed as part of the process outlined in the Disposal Arrangements

for “Relevant Manager authorises destruction”)

File Title

Registration Number (if Corporate File)

Destroy

Retain for second review

Please outline your reason(s) and state why you think the period is

appropriate

Name of Reviewing Officer

Team/Department

Signature Date of Decision

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APPENDIX 7

Second Review Form

SECOND REVIEW FORM FOR CORPORATE FILES

(15 years after first review)

File Title

Registration Number (if Corporate File)

Destroy

Permanently Preserve

Please outline your reason(s) and state why you think the period is appropriate

Signatures Records Officer PRONI Representative

Date of Decision

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APPENDIX 8

Document Control Sheet

Document Title

Author(s)

Document Status

Document Amendment History

Version No. Changes Author Date

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Appendix 9

Records Management Do’s and Don’ts Checklist

Do:

Follow PBNI advice about the security of information set out in the

Records Management Procedures and Guidance (held in the Compliance Section/Records Management on the PBNI intranet) when

you have to remove any papers, files or laptops from the office. Be especially vigilant when you are in transit – keep items with you at

all times. Never leave files, papers or laptops unattended in your car or on public transport. You are responsible for the safety of this information so make sure that it is protected.

When transmitting or sending personal data or other protectively marked information (including information sent electronically) check

that you have the correct addressee details and use an appropriate method to send it. The more sensitive the information or the greater the risk of harm from anyone getting unauthorised access, the more

important it is to consider security issues. Staff should ensure that files or information with a protective marking

are removed from desks when the member of staff responsible for the information is leaving for the day and returned to their designated secure storage.

File electronic documents in Team Drives. Personal information should not be held in team drives.

Remember every email is potentially a PBNI record. Clear out your emails inbox and sent items folder periodically.

Be aware that others may be entitled to see your records (including emails) under Freedom of Information and Data Protection legislation.

Read and follow the procedures set out in the Records Management Procedures and Guidance and make sure you are aware of your

records management responsibilities. Organise your corporate records into registered files.

List corporate files in a File Register and keep the list up to date. File all corporate records in the correct corporate file covers.

Every year, review and dispose of the relevant records in accordance with the PBNI Retention and Disposal Schedule.

Contact the Records Officer with any queries regarding records management.

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Records Management Do’s and Don’ts Checklist

Don’t:

× Remove any protectively marked information from a PBNI office unless

there is a clear business or logistical need to do so. In these circumstances, staff should only remove what is needed for the meeting or visit.

× Leave PBNI information unattended at any time when in transit. × At any time, save protectively marked information relating to the

business of PBNI on your home computer, personal laptop or on a USB stick.

× Keep PBNI records in personal drives or files.

× Leave your computer unattended if logged on – use the password ‘lock

computer’ facility to ensure there is no unauthorised access.

× Name folders or shared drives after yourself or hold information relating to your work in PBNI in personal drives, folders or files.

× Under any circumstances, regardless of urgency, use computer

equipment not owned and operated by PBNI to create, modify, store or transmit information related to offenders, or any other protectively marked information.

× Keep records for any longer than needed. × Keep PBNI corporate information that constitute a record in

unregistered files.

× Keep files that duplicate information held elsewhere in your area (except to meet short-term operational requirements).

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Appendix 10 - Team / Department Codes for Registration Office / Department Code Andersonstown Road ATR

Antrim ANT

Antrim Road ARD

Glengormley GL

Newtownards Road NTR

Ormeau Road ORD

Armagh ARH

Ballymena BM

Coleraine CO

Magherafelt MG

Downpatrick DP

Dungannon DU

Enniskillen EN

Lisburn LIS

Crawford Square CSQ

Limavady Road LIM

Newry NWY

Newtownards NDS

Omagh OMH

Portadown PDN

ISU ISU

PDU PDU

Youth Justice YJ

Victims Unit VU

HMP Maghaberry MBY

HMP Magilligan MGN

HMP Hydebank HBK

Assessment Unit AU

Communications CM

Policy Planning & Business Development PPB

Psychologists PSY

Compliance Unit CU

Human Resources HR

Finance FIN

Senior Management SMT

Information Technology IT

Statistics and Research SR

PIMS Team PIMS

Secretariat ST

Salaries and Wages SW

Creditors CR

Accommodation and Supplies AS

Community Development CD

Travel TR

Health and Safety HS

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APPENDIX 11

Off-site Storage Facility - Procedures The Probation Board currently have an off site storage facility to hold closed sensitive and high risk information. This is to contribute to ensure that it is meeting its statutory obligations under The Public Records Act (NI) 1923, Disposal of Records Order (S.R&O 1925 No.167), the Data Protection Act 1998 and the Freedom of Information Act 2000 including Section 46 - The Lord Chancellor’s Code of Practice for Records Management. Records suitable for off-site storage In order to keep costs to a minimum, there needs to be a restriction on the volume of PBNI records that can be stored at an off-site storage facility. The Retention and Disposal Schedule sets out the timescales for holding all PBNI records. We have identified that records in the following categories are suitable for off-site storage:

(i) Records that have been identified for permanent preservation, and (ii) Records that

fall under the 99 year category such as Schedule 1 offender files, ROSH and Lifer files,

Human Resources records which currently have a 72 year retention period,

Finance records that are retained for more than 7 years and

Records that PRONI have determined, through their review process, should be held for a further 15 years.

The Records Officer can approve holding other files if space is restricted at an office but primarily it is for these records as mentioned above.

Procedure for Retrieval of Files held at Off-site Storage

Occasionally, staff may need to access files that are held in the off-site storage facility. It is possible to retrieve files but there is a cost for this service. Consequently, only files that need limited access should be stored in this facility. Files that require more constant access should be held locally.

Should you require the retrieval of an offender file from off-site storage you must complete the attached form (Form A) and have it authorised by your manager.

Please complete a new Form A for each individual file. If you are requesting an offender file and you are aware that there is more than one file relating to this offender held at the off-site storage facility please indicate this on Form A.

When your request is authorised by a manager this form should be e-mailed to the Records Officer based in the Compliance Section of the Communications Unit in PBNI Headquarters. In the absence of the Records Officer you may also contact the Staff Officer in the Accommodation and Supplies department and the Data

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Protection/Freedom of Information Officer in the Compliance Section of the Communications department. The off-site storage facility is able to securely deliver the selected file(s) to the required location. We have agreed a ‘Timing Schedule’ with them that relates to the timescales for the delivery and collection of the file(s) that we have requested.

The Timing Schedule for retrieving files is as follows:

Monday requests – Wednesday delivery from off site storage

Tuesday requests – Thursday delivery from off site storage

Wednesday requests – Friday delivery from off site storage

Thursday requests – Monday delivery from off site storage

Friday requests – Tuesday delivery from off site storage

Therefore, when a file is requested on a Monday, the off-site storage facility will deliver it on the Wednesday of the same working week. In exceptional circumstances a file can be delivered within a shorter space of time than set out above, but this facility should only be used when absolutely necessary as the cost for this is much greater.

Procedure for returning Files to off-site storage facility

File(s) should be returned to the off site storage facility within 4 weeks of receipt. This should be a reasonable period of time for staff to have obtained the required information. When you no longer require the file you should complete the attached form (Form B) within the 4 week period and send it to the Records Officer. The off-site storage facilty will then be contacted and you will be informed as to when the file(s) will be collected. There may be exceptional circumstances where file(s) are required beyond the 4 week period. In such instances, staff should contact the Records Officer and inform her of this with an indication of when the file(s) will be ready for return to the off-site storage facility. The security of the file for the duration of the time the file is away from the off-site storage facility will be the responsibility of the member of staff who has requested it. The off-site storage provider relevant File (s) will be collected will collect the file(s) once they are ready to be return to the off-site storage facility. We have agreed a ‘Timing Schedule’ with them for the collection of files as follows:

Monday requests – Wednesday collections

Tuesday requests – Thursday collections

Wednesday requests – Friday collections

Thursday requests – Monday collections

Friday requests – Tuesday collections Therefore, if contacted on the Monday, the file will be collected on the Wednesday of that week.

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This process and the attached forms are available on the Compliance section on the PBNI Intranet. If you require clarification about this procedure, please contact the Records Officer, Compliance Section, Communications Unit.

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FORM A - FORM FOR RETRIEVAL OF FILES FROM OFF-SITE STORAGE

FILE REGISTRATION NO (where applicable): ________________________ FILE TITLE/NAME OF OFFENDER: __________________________________________________________ NUMBER OF FILES (if appropriate) __________________________________________________________ WHERE WAS THIS FILE HELD IN PBNI? ___________________________________________________________

FILE REQUESTED BY:___________________________________ DATE REQUESTED:_________________________________________

AUTHORISED BY:_______________________________________ DAY & DATE off site storage CONTACTED:_______________________ CONTACTED BY: _______________________________

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FORM B - FORM FOR COLLECTION OF FILES BY OFF-SITE STORAGE

FILE REGISTRATION NO (where applicable): ________________________ FILE TITLE/NAME OF OFFENDER: __________________________________________________________ DATE FILE RECEIVED FROM STORAGE ___________________ NUMBER OF FILES (if applicable): ____________________________________________ FILE READY FOR COLLECTION ON:____________________________

DAY & DATE OFF-SITE FACILITY CONTACTED:_______________________ CONTACTED BY: _____________________________________________

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APPENDIX 12

SOURCES These standards detail the records management policies and procedures, which PRONI expect of public authorities in Northern Ireland.

PRONI has provided guidance on:

Filing Systems (NIRMS 1)

Filing Practices (NIRMS 2)

Disposal Scheduling (NIRMS 3)

Reviewing Procedures (NIRMS 4) Located at www.proni.gov.uk Lord Chancellor’s Code of Practice on the Management of Records (Section 46 of the Freedom of Information Act 2000) The Code of Practice provides the benchmark of good record keeping practice. Located at http://www.foi.gov.uk/reference/statCodesOfPractice.htm

British Standard BS ISO 15489-1 2001 This provides standardisation of best practice in records management policies and procedures to ensure that appropriate attention and protection is given to all records and that the evidence and information they contain can be retrieved more efficiently and effectively using standard practices and procedures.

National Archives Appraisal Policy Version 1 August 2004

National Archives Good practice in managing electronic documents (located at www.nationalarchives.gov.uk)

National Probation Service Protective Marking Policy

Home Office handling Protective Marking Guidance (PC66/2003) (located at www.homeoffice.gov.uk )

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Appendix 13

Practice Note

Re: Retaining Handwritten Notes PSRs

Retaining PSRs

Scanning Documents onto PIMS

The Northern Ireland Public Services Ombudsman recently investigated a complaint against PBNI and made a number of recommendations in respect of the management and retention of some records including Pre-Sentence Reports. The purpose of this note is to clarify the practice requirements for staff arising from the Ombudsman’s recommendations.

1. Handwritten Notes PSR’s

Handwritten notes shall only be recorded on lined paper or on a blank ACE document.

All handwritten notes are discoverable either by the Courts and/or as per the requirements of the Data Protection Act, therefore all such notes must be legible and dated, with the authors name visible.

The handwritten notes shall be retained in accordance with PBNI’s Retention and Disposal Schedule. They shall be scanned onto PIMS – following scanning onto PIMS the hard copy shall be destroyed.

2. Retention of Pre Sentence Reports

Following the completion of a PSR, the only version to be retained on PIMS is the version sent to Court. Draft versions are not to be retained on PIMS or in hard copy, post submission to the Courts.

During interviews with clients, staff should not make substantive changes on the draft PSR document. Rather they are to use lined paper and retain (as per 1 above).

3. Scanning on Documents to PIMS

It is PBNI’s preferred practice to scan documents onto PIMS as opposed to keeping paper copies. Staff must ensure that they have successfully scanned on notes, papers and documents before disposing of paper copies. Attached for your convenience is guidance for scanning on documents. Please keep a copy of this Practice Note on your copy of the Best Practice Framework: Section 7.

Hugh Hamill, (Acting) Deputy Director

Paul Doran, Deputy Director

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GUIDANCE FOR ATTACHING SIGNED DOCUMENTS TO PIMS APPENDIX 14 It is PBNI’s preferred practice to scan documents onto PIM’S: as opposed to keeping paper copies. Staff must ensure that they have successfully scanned on notes, papers and documents before disposing of paper copies. 1. Place the document(s) you wish to scan onto either the glass (1 single sided document) or the

feeder (numerous pages/double sided documents ie Deps). Log onto the printer using your Board

pass or nominated passcode and click on the ‘Home’ key which is positioned at the left hand side of

the printer.

2. You will then see the following options (below) displayed on the Printer screen – choose ‘E-mail’

and then hit the green ‘Start’ button.

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GUIDANCE FOR ATTACHING SIGNED DOCUMENTS TO PIMS

3. The printer will then scan the documents

4. Processing and the number of pages will be confirmed

5. Once scanning is complete you can log off the printer.

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GUIDANCE FOR ATTACHING SIGNED DOCUMENTS TO PIMS

6. Once scanned the document(s) will then come through your mailbox as a normal e-mail with the

attachment in PDF format (see example below). Open the Attachment and then save into a

temporary ‘Scanned Documents’ folder within your team drive before attaching onto PIMS.

*PLEASE NOTE - ALL DOCUMENTS SHOULD BE DELETED FROM THE ‘SCANNED DOCUMENTS’ FOLDER

WITHIN YOUR TEAM DRIVE, IMMEDIATELY THEY ARE ATTACHED TO PIMS

YOUR DOCUMENTS ARE NOW READY TO ATTACH TO PIMS (see follow on guidance sheet)

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GUIDANCE FOR ATTACHING SIGNED DOCUMENTS TO PIMS

To ensure any documents electronically attached to PIMS can be accessed it is important they are

saved and attached correctly.

1. Click on ‘File/Save As’ then click on ‘Computer’ and select your ‘T’ Drive and then the

appropriate subfolder within your Team Drive. The document can then be given its filename.

2. Open PIMS, access the Referral, then the Client tab– ensure the Update button is available.

Click on Attachments

3. Type in name of attachment against Caption –

Due to the increased number of electronically attached documents on PIMS client screens it is

important that the ‘caption’ name is appropriately titled so that attachments can easily be retrieved.

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GUIDANCE FOR ATTACHING SIGNED DOCUMENTS TO PIMS

It is recommended that the caption name begins with the referral number then the name of the

document eg: R123456 - Deps

4. Next locate your document, click on the symbol to locate select Computer, then Team Drive

and appropriate sub folder. Once located, select the appropriate file name and double click.

This will copy that file into the Document section.

5. Always select Computer, Team Drive to locate your document. Do not attach any documents

that have ‘shortcut’ against their name or are ‘link’ files as these are only temporary shortcuts or

links to the document and not the document itself.

Select the date from the date field and click on Insert at the bottom of the screen. This will copy

that file into the Attachments file and can be accessed from PIMS when required by double clicking.

Finally always open the newly attached document to ensure that you have attached the correct

document and that it opens.

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RISK ANALYSIS ON SCANNED DOCUMENTS APPENDIX 15

What are we doing?

PBNI received a Report from the Northern Ireland Public Services Ombudsman on 15 March in relation to a complaint made by a person under PBNI supervision. The Ombudsman found there had been maladministration and PBNI put in place the action plan detailed below to deal with the recommendations made and comments made by the Ombudsman.

Action plan point 4:

1. IA should include a risk analysis need of the decision to recognise scanned documents as the record.

PBNI’s Management of Information Policy, based on ICO and Cabinet Office Gudience, clearly states: “PBNI is committed to creating, keeping and managing information that documents its principal activities and its corporate functions in accordance with any statutory laws and regulations. This Policy Statement covers all recorded information, in any form, created, received or maintained by PBNI.” and “Recorded information - any record or document maintained in various formats such as handwritten, typed, e-mailed, electronic, audio and video tapes/discs, databases, maps and any other documentary material held by PBNI in the transaction of its business and retained as evidence of these activities.” Pros and cons of electronic scanned documentation:

Pros Cons

Centrally accessible location Initially time consuming for large documents

Backup of information/disaster recovery

Legibility issues

Space saving Costly in terms of digital space required

No degradation of quality of paper A naming convention needs to be agreed and enforced

Time saving through re-filing Data retention not always complied with

Integrity of information

Green / eco-friendly

Increased security

Following the formal risk analysis it was re-affirmed that scanned documents are recognised as a record.

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GLOSSARY

ACE Assessment Case Management and Evaluation System

DPA Data Protection Act

EDRMS Electronic Document and Records Management Systems

EIR Environmental Information Regulations

ERMS Electronic Records Management System

FOI Freedom of Information

NIRMS Northern Ireland Records Management Standards

NI Standards The Standards set out the levels of service and practice required of PBNI in relation to its assessment, management and supervision of persons who have been made subject to a court order.

PAMS Personnel Administrative Management System.

PBNI Probation Board for Northern Ireland

PRONI Public Records Office of Northern Ireland

PIMS Probation information Management System.

Retention This is the time period for which the information is kept.

Retention and Disposal Schedule

This is a document which outlines all types of records held within PBNI, the period for which such records should be retained and the action required when the retention period has been reached.

ROSH This refers to offenders who have been assessed for risk of harm and risk of re-offending and have been deemed potentially dangerous

Schedule 1 Schedule 1 of the Children and Young Persons (NI) Act 1968 refers to any offence (physical or sexual) against a child (under 18)

Statutory Supervision

Offenders who have gone through the court system and for whom PBNI have a legal obligation to supervise

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